August 26-29, 2014 | Columbus, OHUNITING THE WORLD of WATEROhio WEA-AWWA

2014 Technical Conference & Expo

The Long-Term Lead and Copper Rule Understanding Potential Changes and Impacts on Community Water Systems

UNITING THE WORLD of WATER

Presentation Outline

What changes are being considered under the LT-LCR?

Research Suggests The Current Rule Is Not Capturing Some High Pb/Cu Samples

• Lead service lines (LSLs) contribute 50-75% of lead at the tap [1]

• Elevated lead concentrations in drinking water after partial lead service line replacement (PLSLR) [2]

• Elevated copper concentrations in drinking water from new construction [3,4,5]

• Tier 1 site must be served by a LSL • Samples collected from a LSL • Adding a separate pool for Cu sampling

• More stringent WQPs or phosphate addition benchmark for effective optimization

• Adding a requirement for Cu in the event of a Cu AL exceedance

• Elimination of “test-out” provision

Potential Revisions Being Considered Under the LT-LCR

Public EducationPublic EducationPublic Education

Pb & Cu Tap Sampling Requirements

Pb & Cu Tap Sampling Requirements

Optimized Corrosion Control Treatment

Optimized Corrosion Control Treatment

Optimized Corrosion Control Treatment

Lead Service Line Replacement

Lead Service Line Replacement

Lead Service Line Replacement

• Tier 1 site must be served by a LSL (Scenario 1)• Samples collected from a LSL (Scenario 2)• Adding a separate pool for Cu sampling (Scenario 3)

• Systems must re-optimize if AL is exceeded• More stringent WQPs or phosphate addition benchmark for

effective optimization

• Adding a requirement for copper in the event of a copper AL exceedance

• Elimination of “test-out” provision• Delay replacement until after CCT re-optimization

Potential Revisions Being Considered Under the LT-LCR

Public EducationPublic EducationPublic Education

Pb & Cu Tap Sampling Requirements

Pb & Cu Tap Sampling Requirements

Optimized Corrosion Control Treatment

Optimized Corrosion Control Treatment

Optimized Corrosion Control Treatment

Lead Service Line Replacement

Lead Service Line Replacement

Lead Service Line Replacement

Who will be affected?

Scenario No. Description

Percent of Systems Above AL with LT-LCR

Changes

Population Impacted

(in Millions)

1 Changing sample site Tier Definition

2

Sampling Directly from LSLs –Temperature Variation Method

Sampling Directly from LSLs –Standard Volume Flushing Method

Sampling Directly from LSLs –Sequential Sampling Method

3 Targeted Cu Monitoring

Evaluated Three Potential LT-LCR Tap Sampling Requirements to Identify Impacted Systems

Scenario No. Description

Percent of Systems Above AL with LT-LCR

Changes

Population Impacted

(in Millions)

1 Changing sample site Tier Definition 12.5% of systems with LSLs 15.2

2

Sampling Directly from LSLs –Temperature Variation Method

Sampling Directly from LSLs –Standard Volume Flushing Method

Sampling Directly from LSLs –Sequential Sampling Method

3 Targeted Cu Monitoring

Evaluated Three Potential LT-LCR Tap Sampling Requirements to Identify Impacted Systems

Scenario No. Description

Percent of Systems Above AL with LT-LCR

Changes

Population Impacted

(in Millions)

1 Changing sample site Tier Definition 12.5% of systems with LSLs 15.2

2

Sampling Directly from LSLs –Temperature Variation Method

9.5% of systems with LSLs 11.8

Sampling Directly from LSLs –Standard Volume Flushing Method

54.5% of systems with LSLs 74.0

Sampling Directly from LSLs –Sequential Sampling Method

70.5% of systems with LSLs 96.4

3 Targeted Cu Monitoring

Evaluated Three Potential LT-LCR Tap Sampling Requirements to Identify Impacted Systems

Scenario No. Description

Percent of Systems Above AL with LT-LCR

Changes

Population Impacted

(in Millions)

1 Changing sample site Tier Definition 12.5% of systems with LSLs 15.2

2

Sampling Directly from LSLs –Temperature Variation Method

9.5% of systems with LSLs 11.8

Sampling Directly from LSLs –Standard Volume Flushing Method

54.5% of systems with LSLs 74.0

Sampling Directly from LSLs –Sequential Sampling Method

70.5% of systems with LSLs 96.4

3 Targeted Cu Monitoring 8% of systems with high alkalinity and low pH 10.9

Evaluated Three Potential LT-LCR Tap Sampling Requirements to Identify Impacted Systems

What are the compliance options and how much will it cost?

Three Corrosion Control Methods Identified as Optimum in the Current LCR

Carbonate Passivation

• Metal complexes on pipe surface

• Prevents metal release

Inhibitor Addition

• Phosphates (orthophosphate or blends)

• Silicates

Carbonate Precipitation

• Calcium carbonate coats pipe surface

• Does not form uniform, non-porous layer

Carbonate Precipitation Not Considered An Effective Strategy for LT-LCR Compliance

Treatment Strategies Considered for Compliance with the LT-LCR

Systems not adding phosphate

Raise pH and/or

alkalinityAdd

phosphate

Add phosphate and adjust

pH

Systems adding

phosphate

Boost phosphate Lower pH

Baseline National Cost is Significant

$25

$120

$48

$73

$168

$0

$20

$40

$60

$80

$100

$120

$140

$160

$180

$200

1 2 3 1+3 2+3

Ann

ual C

ost (

$Mill

ion)

Scenario

Multiple Uncertainties Impact Cost

Lead service line occurrence

LSL sampling method

Phosphoric acid cost

Systems impacted by copper monitoring

National Cost Impacts of Uncertainty

$0

$50

$100

$150

$200

$250

$300

$350

$400

1 2 3 1+3 2+3

Tota

l Ann

ual C

ost (

$Mill

ion)

Scenario

Total Annual Cost of Regulatory Scenario ($ Million) 1 2 3 1+3 2+3

Baseline $25 $120 $48 $73 $168Range $11 - $49 $50 - $272 $30 - $107 $30 - $156 $50 - $379

National Cost Equivalence of Full Lead Service Line Replacements (FLSLRs)

Scenario 1 –Changing Sample Site Tier Definition

Scenario 2 –Sampling Directly

from LSLs

Baseline National Cost $25,000,000 $111,000,000

FLSLRs per Year Nationally($5000/replacement) 5,000 22,000

Total Population Affected by FLSLRs 15,000(<0.01%)

66,000(<0.04%)

Total Population Affected by OCCT Upgrade

Up to 42,000,000(<1% - 14%)

Up to 150,000,000(2% - 49%)

What are the unintended consequences we need to consider?

Potential LT-LCR Unintended Consequences

Description of Potential UICOCCT Strategy

pH/Alkalinity Adjustment

Phosphate Addition

Increased scaling resulting in loss of hydraulic capacity or additional system maintenance Reduced distribution system disinfection performance Change in DBP speciation/concentrations Required joint Stage 2 DBPR and LT-LCR compliance Increased phosphorus loading at POTW, with increased sludge production Need for additional operator certification/staffing

National Cost Impacts of UICs

$0

$100

$200

$300

$400

$500

$600

1 2 3 1+2 1+3 2+3

Tota

l Nat

iona

l Cos

t ($M

illio

ns)

Scenario

Potential Cost of UICsAnnual Cost of OCCT

National Cost of Regulatory Scenario ($ Million) 1 2 3 1 +2 1 + 3 2 + 3

Annual OCCT Cost $11 - $49 $50- $272 $30- $107 $50- $272 $30- $156 $50- $379

Annual UIC Costs $19 $77 $28 $77 $47 $106

Total Annual Cost $11 - $68 $50 - $349 $30 - $135 $50- $438 $30 - $203 $50 - $485

What’s next for the LT-LCR and PWSs?

• Goal: • Incorporate changes that will make the rule

more protective of public health and are implementable

• Focus:• Sampling requirements• Optimized corrosion control treatment• Public education for copper• Lead service line replacement

• Anticipated Schedule: • 9 – 12 month stakeholder process began

March 2014• Proposed rule expected 2015• Final rule sometime in 2016 – 2017

Regulatory Framework for LT-LCR

What Can You Do To Prepare?

Manage and review historical data to:

• Establish a baseline• Assess potential compliance with anticipated changes

Conduct additional sampling or testing, where possible

Acknowledgements

AWWA and Project Steering Committee MembersSteve ViaStephen Estes-SmargiassiSteve SchindlerMatt SmithJeff Swertfeger

Participating public water systems

ARCADIS TeamChris HillSean Chaparro Roger Arnold Doug Owen

Thank you!Rebecca Slabaugh, PE, ENV SPARCADISRebecca.Slabaugh@arcadis-us.com(317) 231-6500